1. Intoduction
2. Detailed
comments on the draft report
1.
Introduction
PDCN welcomes the
opportunity to comment on the first draft of the
report of the Wheelchair Accessible Taxi
Taskforce. We look forward to contributing
further to the discussions that will flow from
it.
We are generally
supportive of and encouraged by the 'big
picture' presented by the draft. We particularly
welcome the approach described by the Taskforce
chairperson in his Foreword. We are wholly
committed to the focus described as:
- "Defining a
realistically achievable goal and delivering
recommendations for an industry adjustment
plan to reach this goal over an appropriate
timeframe." 1
We remind all stakeholders
that the DDA Disability Standards for Accessible
Transport already describe outcomes required by
law: equal response times for booked services of
wheelchair accessible taxis by December 2007. In
addition, however, we concur with comments in
the draft report about the changing demographic
profile of the population of NSW. We are certain
that operators and regulators need to take
decisions now to prepare the fleet and personnel
in the industry for the services that will be
needed ten years from today and
beyond.
2.
Detailed comments on the draft
report
a.
Data
We believe that the final
report (and the draft) should offer more (and
more robust) data about the industry. We
appreciate that gathering data is not always
easy and, for that reason, we welcome the facts
and figures that have been presented.
Nevertheless, PDCN feels that the reports would
benefit from a fuller set of comprehensive data
based on verifiable information.
These questions, for
example, if answered, would assist all
stakeholders to understand better the current
reality of wheelchair accessible taxi service
provision. We would have a better context for
assessing the efficacy and/or worth of any
recommendations that are put to the
Minister.
- What is the current
status of all WAT licences?
- How many have been
issued?
- How many are
currently in use?
- What is happening
to licences that have been issued but are
not currently in use?
- Who was issued with
NEXUS plates?
- Who currently holds
NEXUS plates?
- How is the
difference explained?
- How well does the
WAT service system perform?
- How many WAT jobs
does each WAT perform each
week?
- Are there WAT
drivers / operators who never do WAT
jobs?
- What are the
response time statistics for WAT vehicles?
(We assume this data can be extracted from
the performance data published by IPART
this year)
- What proportion of
WAT jobs originate through the 0200
Network?
- What proportion of
WAT jobs originate through private
arrangements?
b. Operating
costs
We acknowledge that
Professor Fitzgerald will be working on the
production of a viability study of wheelchair
accessible taxi operation. We welcome that
effort.
Notwithstanding Professor
Fitzgerald's task, however, we believe that the
interim report of the taskforce should indicate
(if not report on at this stage) costs and
benefits of WAT operation that require
investigation. For example:
- Are there 'pay ins' or
charges levied on drivers of WAT vehicles
that are not levied on drivers of non-WAT
vehicles?
- Is the
industry-imposed requirement that WAT
services be booked through a central booking
service now a restraint on trade?
- If the booking of WATS
were to be 'de-regulated' (i.e. normalised to
the extent that customers would book WATs
directly through Network / Cop-operative /
private arrangements rather than a
centralised booking service) what would be
the effect on 'pay ins', charges and other
costs currently levied on WAT drivers? (E.g.
what would be the financial benefit to
drivers of no longer requiring a second radio
network in the cab?)
- What actuarial
evidence exists to support the contention
that WAT vehicles are more expensive to run
and service than non-WAT
vehicles?
- What are the different
operating costs of different types of WAT
vehicle?
c.
Incentives
PDCN is on record (in all
our WAT related documents of the last five
years) as acknowledging the valuable and welcome
subsidies and incentives made available by the
State Government. The subsidy to the licence
fee, alone, is hugely valuable to licence
holders.
We believe that the draft
report is correct to identify drivers as the key
target group. We have said in all our documents
that action needs to be taken to distribute
subsidies more equitably among industry
stakeholders. We have no particular view, at
this time, on any of the proposals currently
being discussed, although we did express clear
opinions in favour of a driver incentive in
our
last submission to IPART.
We support the
introduction of an incentive for drivers of WAT
vehicles and (we would add) radio operators who
put-out the work to drivers. It is important,
however, that any incentive be developed within
these parameters (there may be others too):
- Wheelchair users must
not be personally penalised by any incentive
scheme (to do so would breach the provisions
of the DDA).
- Incentives ought to be
tied to some performance standard (as in
South Australia, where the 'set down' fee is
paid only if the customer is picked up within
half an hour of the booked time).
- The introduction of a
'set down' fee or driver incentive must mean
that the current arrangements with regard to
loading or waiting time cease. If drivers are
to receive an incentive fee for carrying
wheelchair users, the meter must not be
switched on until after loading is completed
and the driver is ready to move off. In
short, drivers can't have their loading time
cake and eat a 'set down' cookie
too.
d. Enforcement of
regulations
We have welcomed
improvements made in the last two years to the
enforcement regime with regard to WAT services.
We remain convinced, however, that more could
still be done. In short we believe that more
rigorous policing of WAT licence operations and
driver behaviour is essential. This is true with
the fleet as it is now (7.5% wheelchair
accessible) and will be just as true when the
fleet is universally accessible.
We acknowledge that many
drivers perform sterling work as WAT drivers. We
want more of that.
We believe, however, that
it is the industry's best known 'secret' that a
small but significant proportion of WAT licences
on WAT vehicles are held by people who view the
licence as nothing but a cheap route into the
industry. In some cases the vehicles are never
or almost never deployed to perform WAT work for
passengers in wheelchairs. The enforcement
regimes of State authorities should ensure that
this malpractice loophole is closed.
We believe, therefore,
that the draft and final reports should ask and
answer enforcement questions such as
these:
- Are performance
standards monitored effectively
enough?
- Does every network use
GPS as a tool for directing WAT drivers to
wheelchair users?
- Are WAT licence
holders monitored to ensure that they and/or
their drivers carry out WAT work as intended
by the licence, the licence subsidy and
regulations?
- Would a quota system
(minimum number of WAT jobs per shift / week)
be effective?
- Could the Taxi and
Hire Car Bureau develop more effective
policing regimes?
- Can the RTA be more
assertive and effective in monitoring the use
of restraint / safety equipment?
- Are the enforcement
regimes making effective use of
penalties?
- How many WAT
licences have been revoked for abuse of
regulations / licence
conditions?
- Are statistics kept
on abuse of WAT licence
obligations?
- Is there an
independent complaints mechanism for 0200
complaints?
e. Operating
benefits
It is clear to PDCN that
vehicles that can accommodate wheelchair users
(one or more) have access (potentially and in
reality) to the whole taxi market and to more
segments within that market than taxis that are
not wheelchair accessible. It is important that
the draft report and final report to the
Minister begin to address and promote cultural
change within the industry. For
example:
- No segment or
sub-section of the customer base for taxis is
excluded from access to service by wheelchair
accessible taxi design.
- Vehicles that are
designed to accommodate wheelchair users (one
or more) can and do look indistinguishable
from taxis that exclude wheelchair users.
There is no inherent reason why any WAT
vehicle should discourage passenger use by
non-wheelchair users.
- WAT vehicles have
access to segments of the market that are not
open to non-WAT vehicles. At a time of
reportedly fierce competition in the
industry, expanding into new markets through
deployment of higher standard vehicles makes
good business sense. (For a point of
comparison see the burgeoning segment known
as 'premium services' all of which use more
costly vehicles than so-called standard taxis
in an entirely voluntary development of
higher quality services by the industry
itself).
f. Workforce
issues
We acknowledge that the
taxi industry as a whole faces serious problems
in recruiting and retaining drivers. This is not
just an issue about WAT drivers. It is our
contention that the further integration of taxi
services into community and local transport
culture will work to the benefit of workforce
development.
It is clear from the
announcements of Minister Costa that the State's
transport service system is being appraised with
a view to modernisation. As our population ages
and the need for personalised, often
door-to-door, transport expands, taxis are
likely to play a greater part in development of
the State's transport solutions in the
future.
We can foresee potential
to develop new entrants to the workforce because
of the changes expected over the next thirty
years. There will be new possibilities for
drivers to develop ongoing relationships with
clearly defined communities of passengers (older
people, wheelchair users, others for whom mass
transport options are not currently viable).
This possibility could be the reason for joining
or staying in the industry.
That potential for
'getting to know the customer' should not be
misunderstood, however, with regard to
wheelchair users and WAT drivers. We have often
heard it said that "special" types of people
need to be recruited to work as WAT drivers. We
are not convinced that there is truth in that
observation. We believe it is a product of and
helps to reinforce stereotyped and out-dated
ideas about disability and people with
disability.
In our experience (as
passengers of WAT vehicles) drivers, first and
foremost, need to be skilled and competent
professionals with knowledge and understanding
of their customers and their vehicles. We do not
believe that means drivers of WAT vehicles
should see themselves or be seen as surrogate
social workers, home helps, personal assistants
or nurses for their customers, some of whom may
be wheelchair users.
We believe that it is time
for the training of drivers of WAT vehicles to
be re-appraised. In our view, training should be
provided by an accredited training organisation
with no direct or indirect interest in a taxi
operation. The training provider should
be:
- Independent of any
taxi operator;
- Competent and
experienced in customer care training
delivery;
- Competent and
experienced in transport industry
training;
- Involve competent and
experienced trainers who are also wheelchair
users.
- Probably be accredited
as an RTO.
g. Finally, some
points about the text:
- Throughout the first
draft, the term "wheelchair bound" is used.
It is not accurate, strictly speaking, and we
recommend that "wheelchair user" replace
it.
- PDCN does not doubt
the truth of the "WAT driver experiences"
related on page 18 of the document. We are
absolutely certain, however, that they are
not representative of driver experience. The
text of the report should make it explicitly
clear that the taskforce, as a whole, does
not necessarily believe the accounts to be
representative.
- We note the
observation (on page 24) that there is a
"general view within the taxi industry that
WATs are not a viable business opportunity
and are an imposition to be borne." We don't
doubt that this view is articulated strongly
by some in the industry. We're far from sure,
however, that it's a general view. We look
forward with keen interest, therefore, to
Professor Fitzgerald's study. We will strive
to contribute positively to that
discussion.
- PDCN believes that a
universally accessible fleet is a
realistically achievable goal even without
financial incentives for an industry
adjustment strategy. We remind taskforce
members that entire fleets have been made
wheelchair accessible elsewhere (without
financial incentives to the industry). We ask
taskforce members to note, in particular,
that some of the fleets that have been made
wholly accessible to wheelchair users are
former fleets of sedan vehicles that have,
never before, and do not now use the atypical
'London taxi',
- Notwithstanding the
above, PDCN would support a financial
incentive for the taxi industry in NSW to
adjust to universally accessible vehicles. We
believe that the draft report should note
explicitly the taskforce's agreement that
such a proposal is worthy of further,
detailed consideration.
Dougie Herd
Executive Officer
Physical Disability Council of New South
Wales
Friday, 27th August 2004
